United States v. Quail

HAYNES

Defendant moves the court to allow his sentencing memorandum to be filed today, two days late. The memorandum was due on November 28, 2011. Undersigned counsel found that it took longer than he expected to synthesize two years of work and edit the product into something of reasonable length and comprehensibility.

Respectfully submitted,

HENRY A. MARTIN (BPR #002830)

Federal Public Defender

SUMTER L. CAMP

Assistant Federal Public Defender

Attorneys for Daniel Quail

I hereby certify that on November 30, 2011,1 electronically filed the foregoing Motion to Allow Late Filing with the clerk of the court by using the CM/ECF system, which will send a Notice of Electronic Filing to the following: S. Carran Daughtrey, Lynne T. Ingram, and Byron M. Jones, Assistant United States Attorneys, 110 Ninth Avenue South, Suite A961, Nashville, TN 37203.

HENRY A. MARTIN